Trade and Order Execution Policy - Coinbase Financial Services Europe Ltd

Last Updated: June 17, 2026

Coinbase Financial Services Europe Ltd (hereafter the “Company” or “CBFSE”) is a limited liability Company incorporated in the Republic of Cyprus with registration number HE 350475. The Company is authorized and regulated by the Cyprus Securities and Exchange Commission (hereafter the “CySEC”) to operate as a Cyprus Investment Firm (hereafter the “CIF”) under license number 374/19.

The Company operates under the provisions of Directive 2014/65/EU of the European Parliament and of the Council of 15 May 2014 on Markets in Financial Instruments (“MiFID II”), as transposed into Cypriot Law by the Investment Services and Activities and Regulated Markets Law 87(I)/2017, as amended from time to time (the “Law”). This Trade and Order Execution policy (the “Policy”) sets out the principles the Company applies in accordance with MiFID II, the Law, Commission Delegated Regulation (EU) 2017/565, and the directives and circulars issued by CySEC (collectively the “Best Execution Rules”), the Company is required to take all sufficient steps to obtain the best possible result for its clients ( “Clients” and each a “Client”) when receiving and transmitting orders, and when executing orders on behalf of Clients, taking into account price, costs, speed, likelihood of execution and settlement, size, nature or any other consideration relevant to the execution of the order.

This Policy outlines the Company's guidelines for executing Client trades and orders in financial instruments. Its objective is to consistently achieve the best possible outcome for Clients, ensuring that orders are executed under the most favourable terms available.

The Company is authorised to provide the following investment services in respect of the financial instruments listed in its CySEC licence:

The Company acts on an agency basis for all transactions executed on behalf of Clients and does not take a proprietary principal position against any Client (i.e., the Company is not the Client’s counterparty in any transaction). Clients should refer to the Execution Costs section below and to their account documentation for details on how their transactions are priced. The Company's best execution obligations to Clients remain the same in all cases - to take all sufficient steps to consistently obtain the best possible result when receiving, transmitting and executing orders.

The Company facilitates trading in a range of financial instruments. The specific financial instruments available for trading, together with their key characteristics, specifications, applicable trading conditions, and costs, are published on the Company’s website and/or trading platform (the “Trading Platform”) and may be updated from time to time. Clients should review the relevant product disclosures published on the Company's website and/or Trading Platform before placing any order.

Clients may open and close positions subject to and in accordance with the User Agreement, including within such periods and under such conditions and/or restrictions as the Company may agree with the Client under the User Agreement. Cancellation of orders and/or suspension of a Client’s trading account with the Company is also governed by the User Agreement and will be performed by the Company subject to and in accordance therewith.

Certain financial instruments offered by the Company carry product-specific features (such as contract rolling, cash settlement, funding rates, margin requirements and close-out arrangements). The product-specific terms applicable to each financial instrument are set out in the User Agreement and/or the product disclosures (e.g. Key Information Documents) published on the Company's website and/or Trading Platform. Clients should review these documents carefully before trading.

The Company executes all active Client orders based on its published price. When processing Client orders, the Company adheres to the following conditions: 

To offer Clients flexibility in trade execution, the Company supports a range of order types. Orders may also be subject to time-in-force instructions (for example, Good-Till-Cancelled, Good-Till-Date, Fill-or-Kill or Immediate-or-Cancel). The availability, operation, and parameters of specific order type and time-in-force instructions for each product may vary depending on the financial instrument being traded and the relevant Execution Venue. Clients should refer to the Trading Platform for details of the order types available for each product.

There is no guarantee that any order will be executed at the price indicated at the time it is placed. Market volatility, liquidity, latency and other factors may result in execution at a price more or less favourable than the indicated price. Subject to the User Agreement, the Company will not be liable to any Client where the executed price differs from the price indicated when the order was placed. Clients should ensure they understand the operation and execution risks of each order type before placing an order.

An "Execution Venue" means any regulated market, multilateral trading facility, organised trading facility, systematic internaliser, market maker, liquidity provider, broker, exchange, or other entity performing a similar function to which the Company transmits Client orders or through which Client orders are executed. The Company's objective in selecting Execution Venues is to obtain, on a consistent basis, the best possible result for its Clients, taking into account the execution factors and criteria set out in this Policy. The Company assesses Execution Venues on a case-by-case basis and monitors them on an ongoing basis to ensure they continue to deliver the best possible result for Clients.

The Company transmits or executes Client orders through one or more Execution Venues and/or brokers selected in accordance with this Policy. The current list of Execution Venues and brokers used by the Company for each class of financial instrument is published on the Company's website and/or made available to Clients via the Trading Platform, and is updated from time to time. The list may include venues and brokers located outside the European Economic Area (the "EEA"), including Affiliates of the Company.

The Company currently places significant reliance on the Execution Venues and brokers listed in the Current Execution Venue List, which is published on the Company’s website at www.coinbase.com/cbfse and made available via the Trading Platform, in meeting its obligation to take all sufficient steps to obtain, on a consistent basis, the best possible result for the execution of Client orders. The list is reviewed at least annually and may be updated from time to time. Where the Company adds, removes or replaces an Execution Venue or broker, the Current Execution Venue List will be updated accordingly and Clients will be notified in accordance with this Policy.

The Company may use the services of an Affiliate or a third-party broker or dealer to assist in the receipt, transmission and/or execution of Clients orders, including entities established outside the EEA. The use of an Affiliate or third-party broker does not relieve the Company of its best execution obligations to its Clients. Where the Company uses an Affiliate or third-party broker, it will satisfy itself through appropriate due diligence and ongoing monitoring, that the relevant entity has arrangements in place to enable the Company to comply with its obligations under the Best Execution Rules. 

The Company reviews the Execution Venues and brokers it uses at least annually, and whenever a material change occurs that may affect its ability to continue to obtain the best possible result for Clients. As part of this review, the Company assesses whether alternative venues or brokers should be added, replaced or removed.

When executing Client orders, the Company considers the following criteria on a case-by-case basis to determine the relative importance of execution factors:

When receiving, transmitting and executing Client orders, the Company will take all sufficient steps to obtain the best possible result for Clients, taking into consideration the following execution factors on a case-by-case basis:

For Clients categorized as Retail Clients, the best possible result will be determined in terms of the total consideration, representing the price of the financial instrument and the costs related to execution. The other execution factors (speed, likelihood of execution and settlement, size, nature, and any other relevant consideration) will, as a general rule, be given precedence over the immediate price and cost consideration only to the extent that they are instrumental in delivering the best possible result in terms of total consideration.

For Professional Clients, the relative importance assigned to the execution factors is calibrated to the nature of the Client, the order, the financial instrument and the Execution Venue, and may differ from the approach applied to Retail Clients.

Where a Client is categorized as an Eligible Counterparty, the Company’s obligations differ from those applicable to Retail and Professional Clients, as set out in the Exemptions section of this Policy.

The Company and/or the relevant Execution Venues may operate price-control and volatility-management mechanisms (which may include price limits, circuit breakers, dynamic price-fluctuation limits, trading halts and similar measures) designed to maintain orderly markets and protect market integrity. The specific parameters of these mechanisms are determined and maintained by the relevant Execution Venue, updated from time to time, and made available through the venue's rulebook and/or the Trading Platform.

The Company and/or the relevant Execution Venues may apply position limits as a risk-management and market-integrity measure. Position limits may be applied at the level of the individual Client (taking into account the Client's profile and attested financial information), at the level of a specific contract or product, and on an aggregate basis across the relevant Execution Venue. Position limits are designed to mitigate excessive risk concentration, reduce the potential for market manipulation, and contribute to orderly markets and fair price discovery. The specific position limits applicable to each product are made available to Clients through the Trading Platform and/or the Company's website, and may be updated from time to time.

"Slippage" refers to the difference between the price at which a Client expects an order to be executed and the price at which it is actually executed. Slippage may be positive (resulting in a more favourable execution) or negative (resulting in a less favourable execution). Slippage may arise as a result of market volatility, liquidity, latency, the size of the order, or other market conditions. The Company monitors slippage on an ongoing basis as part of its best execution monitoring framework.

Where applicable to the financial instrument traded, the Trading Platform provides Clients with tools (such as a liquidation-buffer indicator and order-book depth visualisations) to assist Clients in assessing market liquidity and their proximity to liquidation thresholds. Clients should refer to the Trading Platform and the User Agreement for full details.

The Company applies a transparent fee structure for each financial instrument. All fees and charges payable by Clients are published in the Company's Fee Schedule on its website and/or Trading Platform, enabling Clients to assess the cost implications of their trades prior to execution. Fees may vary depending on the Client's classification, the financial instrument and the Execution Venue. For Retail Clients, all costs and charges directly related to the execution of an order form part of the total consideration assessment. 

In addition to execution fees, certain financial instruments may carry ongoing costs (such as funding rates) that accrue during the life of a position and form part of the total consideration of the relevant transaction. Full details are set out in the Company's Fee Schedule, available on the Company's website and/or Trading Platform.

The prices available to Clients via the Trading Platform are derived from the relevant Execution Venue and may be affected by market factors such as volatility and liquidity.

This covers the nature of the order, such as the type of order, the investment amount, the financial instrument in question, and the means of settlement.

The Company’s infrastructure is designed to optimize data processing and minimise latency. Order latency is monitored on an ongoing basis as part of the Company’s best execution monitoring. 

The Company's order-routing arrangements are designed to direct Client orders to the selected Execution Venue(s) on terms which take into account available prices, order size, and the likelihood of execution and settlement. Settlement (including, where applicable, cash settlement of derivative contracts) is performed in accordance with the rules of the relevant Execution Venue and the relevant clearing house.

The Company's best execution obligations as set out in this Policy are subject to the following exemptions and qualifications:

a. Eligible Counterparties

Where a Client is categorized by the Company as an Eligible Counterparty, the Company is not required to comply with the best execution obligations set out in Article 27 of MiFID II in respect of transactions concluded with, or services provided to, that Client.

b. Specific Client Instructions

Where a Client provides the Company with a specific instruction in relation to an order, or any particular aspect of an order (including, without limitation, an instruction relating to the timing, venue or manner of execution), the Company will execute the order in accordance with that instruction to the extent reasonably possible. In doing so, the Company will be deemed to have satisfied its best execution obligation in respect of the part or aspect of the order covered by the Client's specific instruction. Clients should be aware that following such instructions may prevent the Company from taking the steps that it has designed and implemented under this Policy to obtain the best possible result in respect of the elements of the order covered by those instructions.

Where the Company offers leveraged products, it applies maximum leverage limits per product type in accordance with applicable regulatory requirements and its internal risk-appetite framework. The maximum leverage applicable to each product is published on the Company's website and/or Trading Platform, and is made available to Clients prior to the execution of any order.

Leverage limits are applied at multiple levels, including (i) the individual account level and (ii) on an aggregate basis across the relevant Execution Venue. Once an applicable leverage limit is reached, no further high-leverage positions will be matched. The Company also monitors leveraged exposures on a post-trade basis through its stress-testing framework.

Where applicable, Negative Balance Protection is offered on a per-account basis to Retail Clients. In the event that a Client’s losses result in a negative balance in such Client’s account with the Company, the Company will not seek to recover those losses from assets held outside the Client’s account with the Company.

Clients are also offered the protection of the margin close-out rule. The Company will close one or more of a Client's open positions if the combined total of funds, assets, and unrealized net profits in their trading account falls below a risk-adjusted threshold. This threshold is typically set at 66% of the initial margin required for those open positions. However, certain market conditions or the specific nature of positions may require different thresholds or considerations. For full details on the Company's controls, mechanics, rights, and obligations, Clients should consult the User Agreement.

In accordance with MiFID II and applicable CySEC requirements, the Company maintains records of all Client orders and transactions for a minimum of five (5) years. Where required by CySEC, this period may be extended up to a maximum of seven (7) years.

This Policy is reviewed at least annually, and whenever a material change occurs that may affect the Company's ability to continue to obtain the best possible result for Clients on a consistent basis. Where such a material change arises, the Company will assess its impact and consider appropriate adjustments to the relative importance of the execution factors and to its execution arrangements.

For the purpose of this Policy, a "material change" means a significant event that could affect the parameters of best execution, including (without limitation) price, cost, speed, likelihood of execution and settlement, size, nature, or any other consideration relevant to the execution of orders. It also includes amendments to applicable law (including, the Law) that may affect the Company's ability to obtain the best possible result for its Clients.

Clients provide their consent to this Policy upon accepting the User Agreement and establishing a contractual relationship with the Company. Subsequently, Clients are deemed to consent to any future updates of this Policy if they continue to engage in transactions covered by this Policy after such updates. The Company will also communicate any significant changes to this Policy to all Clients as soon as practicable, using one or more of the following channels: email, the Company’s website and/or its Trading Platform.

The Company reserves the absolute right to amend, modify, alter and update this Policy (or any part thereof) and its execution arrangements, if and whenever it is required to do so. 

Please contact the Company at cbfse-compliance@coinbase.com for any questions and/or request for additional information you may have in connection with this Policy or any matter discussed herein.